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Section 147

Latest Articles


Addition Deleted Due to Lack of Corroborative Evidence in Search-Based Case

Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...

April 21, 2026 507 Views 0 comment Print

Sections 147 & 148 of Income-Tax Act: Reassessment From ‘Reason to Believe’ to ‘Information’

Income Tax : A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods ...

February 28, 2026 873 Views 0 comment Print

Jurisdiction for Reassessment Notices Clarified to End Faceless AO Disputes

Income Tax : The Finance Bill, 2026 clarifies who can issue notices under sections 148 and 148A. It confirms that only jurisdictional Assessing...

February 2, 2026 2844 Views 0 comment Print

Can Penalty be Levied on Delayed Annual GST Return?

Goods and Services Tax : The court held that once late fee is imposed for delayed annual return filing, a further general penalty is not permissible. Secti...

January 20, 2026 18258 Views 2 comments Print

Reassessment Quashed as Limitation Ran From Original Assessment, Not Revision

Income Tax : The issue was whether an assessment could be reopened after four years. The Court held that full disclosure by the taxpayer barred...

January 8, 2026 423 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2193 Views 0 comment Print

Budget 2024: Amendments to Income-tax Assessment & Reassessment Provisions  

Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...

July 23, 2024 4314 Views 0 comment Print

Request to clarify on SC judgement on Section 148 notices

Income Tax : Income Tax Gazetted Officers’ Association requested CBDT to issue Clarification in respect of the judgement of Hon’ble Supreme...

May 12, 2022 7458 Views 0 comment Print

Indiscriminate Income Tax notices without allowing reasonable time

Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...

March 20, 2022 13332 Views 0 comment Print

Extend Time Limit for Income Tax Assessment time barring on 31.3.2022

Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...

March 20, 2022 42774 Views 2 comments Print


Latest Judiciary


Section 68 Additions: Favourable Remand Report Shields Assessee

Income Tax : The issue was deletion of additions on unsecured loans treated as unexplained cash credits. The tribunal upheld deletion, holding ...

May 2, 2026 90 Views 0 comment Print

Delay Condoned with Cost: ITAT Grants Fresh Chance, Slams Non-Compliance

Income Tax : The issue involved dismissal of appeal due to delay and non-appearance. The tribunal condoned the delay citing medical reasons and...

May 2, 2026 111 Views 0 comment Print

Reassessment After 4 Years Quashed as No Failure to Disclose Material Facts: Bombay HC

Income Tax : The issue was whether reassessment could be initiated after four years without fresh evidence. The court held such reopening inval...

May 2, 2026 99 Views 0 comment Print

Reassessment Quashed for Wrong Sanction: ITAT Bangalore Strikes Down 147 Order for Breach of Section 151

Income Tax : The issue was whether reassessment notice issued without approval from the correct authority is valid. The tribunal held it invali...

May 2, 2026 93 Views 0 comment Print

Reassessment Notice Time-Barred as Issued Beyond Limitation Period: Karnataka HC

Income Tax : The Court held that reassessment proceedings must be initiated within the statutory time limit. It found the notice issued after t...

May 1, 2026 453 Views 0 comment Print


Latest Notifications


ITO doesn’t have jurisdiction to issue notice to NRI: ITAT Chandigarh

Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...

April 11, 2025 5745 Views 0 comment Print

Central Government Rescinds 6 Central Excise Notifications issued in 2022

Excise Duty : Notification No. 29/2024-Central Excise rescinds six 2022 excise notifications in the public interest, effective immediately. Deta...

December 2, 2024 813 Views 0 comment Print

Instructions to AO’s for initiating section 147 proceedings in I.T. e-Verification cases

Income Tax : Learn how to initiate proceedings under section 147 of the IT Act in e-Verification cases. Detailed instructions for Assessing Off...

March 19, 2024 10272 Views 0 comment Print

Instructions to AO’s for initiating Section 147 proceedings in e-Verification cases

Income Tax : Explore e-Verification Instruction No. 2 of 2024 from the Directorate of Income Tax (Systems). Detailed guidelines for AOs under I...

March 1, 2024 5784 Views 0 comment Print

Limitation date for reopening cases related to Ashish Agarwal judgment

Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...

February 6, 2023 5880 Views 0 comment Print


DDT cannot be demanded from recipient of interest income: Delhi HC

August 22, 2024 561 Views 0 comment Print

Delhi High Court held that Dividend Distribution Tax (DDT) is liable to be paid by the company which declares, distributes or pays the same. Petitioner, herein, has received interest income from Non-convertible debentures and accordingly cannot be subject to DDT.

Addition towards unexplained cash credit u/s. 68 unwarranted as already declared and taxed as sales: ITAT Ahmedabad

August 22, 2024 1593 Views 0 comment Print

ITAT Ahmedabad held that addition towards unexplained cash credit under section 68 of the Income Tax Act unwarranted as the amount represents sales already declared and taxed. Thus, income already offered for taxation cannot be taxed again as unexplained cash credit.

General order of approval by PCIT for action u/s. 147/148 invalid: Delhi HC

August 22, 2024 1278 Views 0 comment Print

Delhi High Court held that mechanical approval granted by PCIT, vide general order of approval for all the 111 cases without satisfactorily record, for action under section 147/148 of the Income Tax Act is not valid.

ITAT held revision u/s 263 could not address issues beyond limited scrutiny under CASS

August 22, 2024 1308 Views 0 comment Print

Assessee-partnership firm had filed its income tax return declaring income. The case was selected for limited scrutiny, focusing on the issues such as investment in immovable property and share capital/other capital.

Notice u/s. 148 cannot be issued after expiry of four/six years: Delhi HC

August 22, 2024 2802 Views 0 comment Print

Delhi High Court held that that no notice under section 148 of the Income Tax Act shall be issued if four years “but not more than six years” have elapsed from the end of the relevant assessment year.

Filing of Form 10B is a procedural requirement & should not negate substantive claim of exemption

August 19, 2024 1257 Views 0 comment Print

Delhi ITAT rules that the requirement of filing Form 10B is procedural, allowing Section 11 exemption for an educational trust despite delayed filing.

Ex-Parte Order Without Adjudication on Merits is Unsustainable: ITAT Ahmedabad

August 18, 2024 714 Views 0 comment Print

ITAT Ahmedabad held that passing of ex-parte order by CIT(A) without adjudicating issues on merits, such order is not sustainable in the eyes of law keeping in view provisions of Section 250(6) of the Income Tax Act.

Section 153A Addition Valid Only if Based on Material Seized during search: ITAT Kolkata

August 18, 2024 648 Views 0 comment Print

ITAT Kolkata held that additions u/s. 153A of the Income Tax Act could only be made on the basis of seized material found during the course of search. Thus, making additions in regular assessment without any incriminating material relating to said addition not justified.

Passing of Section 148A(d) order based on fresh ground untenable: Delhi HC

August 17, 2024 2658 Views 0 comment Print

Delhi High Court held that passing of order by the revenue under section 148A(d) of the Income Tax Act on the basis of fresh ground which was never taken up with the assessee in the notice is untenable in law.

Section 68 Addition Justified Due to Unproven Genuineness & Creditworthiness: ITAT Ahmedabad

August 17, 2024 891 Views 0 comment Print

ITAT Ahmedabad held that genuineness of transaction, creditworthiness and identity of creditors not proved, hence addition u/s. 68 of the Income Tax Act towards unexplained credit duly sustained.

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